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The Clean Air Task Force argues that the EPA's proposed particulate matter (PM2.5) standards fail to provide an adequate margin of safety, potentially resulting in 10,000 more avoidable deaths per year than a more stringent 12 ug/m3 annual standard. The testimony asserts that protective standards are achievable through affordable technologies, specifically targeting sulfur dioxide (SO2) from power plants and carbon emissions from diesel fleets. It criticizes the Clean Air Interstate Rule (CAIR) for providing reductions that are "too little, too late" and for creating regulatory barriers that discourage states from pursuing additional cost-effective power plant reductions. The document advocates for a national SO2 cap of 2 million tons per year and the full funding of the Diesel Emission Reduction Act of 2005 to facilitate the retrofit of existing diesel engines.

The Clean Air Task Force (CATF) defends its analysis of diesel health impacts against accusations of "junk science" by Jones Day. CATF asserts that its methodology is based on EPA-approved standards and widely accepted epidemiological research, estimating that a national diesel retrofit program could avoid approximately 91,000 deaths between 2005 and 2030.

The document reports that engine crankcase emissions are the primary source of PM2.5 mass in conventional school bus cabins, while the tailpipe is the main source of ultrafine particles, black carbon, and particulate polycyclic aromatic hydrocarbons. Research across four US cities indicates that while diesel particulate filters (DPFs) and ultra-low sulfur diesel (ULSD) reduce ultrafines and black carbon to ambient levels, they do not significantly reduce PM2.5. The installation of a closed-crankcase filtration device, specifically the Donaldson Spiracle™, was found to be critical and necessary to reduce cabin PM2.5 levels to near ambient levels across all tested bus and fuel combinations.

The document advocates for the International Maritime Organization (IMO) to strengthen MARPOL Annex VI by introducing rigorous limits on nitrogen oxides (NOx), sulphur oxides (SOx), and particulate matter (PM) for all ships. It provides evidence that current shipping emissions are under-regulated and cause significant public health and environmental damage, while asserting that advanced control technologies—such as selective catalytic reduction (SCR) and humid air motors (HAM)—make substantial reductions feasible and cost-effective. The submission highlights regional regulatory trends in the European Union and California as precursors to the need for a consistent global standard and urges the adoption of shore-side power standardization.

The Clean Air Task Force (CATF) advocates for the Diesel Emissions Reduction Act of 2005 (DERA), a proposed $1 billion federal grant and loan program to reduce diesel fine particle (PM2.5) emissions. CATF highlights that diesel exhaust causes 21,000 premature deaths annually and that existing engines will remain in service for decades, necessitating funding for retrofits, rebuilds, and repowerings to meet air quality standards and provide immediate climate benefits by reducing black carbon.

The report quantifies the health damages caused by diesel particulate matter (PM2.5) and other emissions across the U.S., highlighting significant risks of premature death, lung cancer, and respiratory illness. It estimates that 21,000 people die prematurely each year in the U.S. due to mobile diesel sources. The document proposes a three-phase retrofit strategy to reduce diesel PM by 85% by 2020, which could avoid approximately 91,000 premature deaths by 2030. It identifies urban areas and 'hotspots'—such as near bus depots and highways—as having significantly higher risks than rural areas. The report also details the effectiveness of retrofit technologies, such as diesel particulate filters (DPF) and closed crankcase filtration, particularly for improving air quality inside school buses.

The analysis of monitoring data at the Navajo Mine contradicts BHP Billiton's claims of negligible environmental impact, finding elevated ash-constituent parameters in groundwater and significantly higher concentrations of TDS, SO4, pH, selenium, and boron downstream in the Chaco River basin compared to upstream.

The document assesses the environmental and health impacts of shipping emissions, noting that they are significantly less regulated than land-based sources. It provides data on global and regional emission inventories, specifically for Europe and the United States, and compares these to land-based mobile sources. The report details several cost-effective mitigation strategies, including the use of low-sulphur fuel, seawater scrubbing, engine modifications, selective catalytic reduction (SCR), and shore-side electrical power ('cold ironing').

The report documents the presence of toxic metals in surface and groundwaters downstream from two coal combustion waste (CCW) disposal sites in Preston County, West Virginia: the Stacks Run Refuse Site Extension and the Albright site. Despite the use of alkaline fluidized bed combustion (FBC) ash, which is often believed to prevent the dissolution of toxic chemicals, the report finds that very high levels of selenium and thallium were detected at the Stacks Run site nearly a decade after disposal began. The document argues that current monitoring practices by the West Virginia Department of Environmental Protection (WVDEP) are insufficient and calls for enforceable regulations to protect water resources.

The report estimates that diesel fine particle pollution causes approximately 21,000 premature deaths annually in the U.S., with significant risks of lung cancer, heart attacks, and asthma. It argues that while EPA regulations for new engines starting in 2007 are positive, the long lifespan of existing diesel vehicles (nearly 30 years) necessitates immediate retrofit actions. The document proposes a reduction target of 50% by 2010, 75% by 2015, and 85% by 2020, which could save nearly 100,000 lives by 2030. Recommended solutions include diesel particulate filters (DPF), Ultra Low Sulfur Diesel (ULSD), and anti-idling ordinances.

The testimony by the Clean Air Task Force (CATF) urges the U.S. Senate to oppose the Clear Skies Act (CSA), claiming its emission caps for sulfur, nitrogen, and mercury are too weak and implemented too late to protect public health and the environment. CATF presents modeling showing that alternative proposals, such as the Clean Power Act, would result in significantly fewer deaths by 2020 with negligible increases in retail electricity prices. The document further argues that CSA fails to address carbon dioxide emissions from power plants and would effectively repeal critical Clean Air Act provisions, including New Source Review and visibility protections for National Parks. It concludes that the EPA already possesses the authority to achieve greater gains through existing rules like the Clean Air Interstate Rule (CAIR) and mercury MACT standards.

The study identifies two primary sources of in-cabin pollution in conventional school buses: the tailpipe and the engine crankcase. It finds that while diesel particulate filters (DPF) combined with ultra-low sulfur diesel (ULSD) eliminate ultrafine particles, black carbon, and PAH, they do not reduce fine particulate matter (PM2.5) because that pollutant originates from the crankcase. The most effective solution for comprehensive elimination of all measured particles is the combination of a DPF, ULSD, and a Donaldson Spiracle closed-crankcase filtration device.

The document describes how automated air/fuel ratio (AFR) controls can optimize the operation of natural gas engines to reduce fuel consumption and emissions. It highlights a case study where the installation of the REMVue system on 51 engines in the Gulf of Mexico led to fuel savings of 18-24% and a reduction of 128 Mcf of methane emissions per unit annually. The economic analysis indicates a total cost of $6.1 million for the project, with an average installation cost of $120,000 per unit and a calculated payback period of 1.4 years based on fuel savings.

The document outlines how the use of monitoring equipment, process models, and regular maintenance of heat exchangers in cryogenic Nitrogen Rejection Units (NRUs) can reduce methane loss in vent streams. It highlights a specific case where process adjustments reduced methane content in the vent stream from 5% to 2%, resulting in significant gas recovery.

The document outlines a method for recovering gas from pipeline pigging, where liquids are removed from gathering systems using pigs. It details the necessary equipment, such as vapor recovery compressors and storage tanks, and provides economic data showing that small recovery systems can be installed for approximately $24,000 with annual operating costs exceeding $1,000.

The document outlines a method to capture methane and other pollutants from condensed liquids at the first compressor station of transmission pipelines. By using gas combustion devices to burn off gases released when liquids are moved to atmospheric pressure storage tanks, operators can reduce emissions. One partner, Columbia Gulf Transmission, reported saving 334,000 standard cubic feet of methane annually from two condensate storage tanks.

The document outlines the practice of capturing 'casing head gas'—methane and other gases that accumulate in the annular space between the casing and tubing—by routing it into a vapor recovery unit (VRU) instead of venting it to the atmosphere. This approach is applicable to wells producing via tubing without packing units and leverages the similar pressure and composition of casing head gas and tank emissions. One reported case by Marathon Petroleum showed an average annual recovery of 7,300 thousand cubic feet of methane over five years, which is equivalent to approximately 10,000 thousand cubic feet of gas containing 73% methane. Economically, the recovery of this gas can offset the costs of piping and increased electricity required for the VRU to inject gas into a 100 psi system, with one partner reporting an electricity cost increase of 3,400 USD per year at a rate of 7.5 cents per kWh.

The document outlines a practice reported by Chevron U.S.A. Production Company to replace methane-rich natural gas used for blanketing water storage tanks with produced CO2-rich gas. This conversion prevents the formation of explosive mixtures in tanks while reducing the venting of methane into the atmosphere. A specific implementation across nine units at a water treatment plant resulted in an annual saving of 32,600 thousand cubic feet of methane gas. The document notes that while CO2-rich gas is a better alternative, it can form acid when dissolved in produced water, necessitating internal tank lining to prevent corrosion.

The document outlines the use of electronic flare ignition devices to replace traditional continuous or intermittent flames in flare stacks, preventing the release of unburned methane and volatile organic compounds (VOCs) when flames are extinguished by wind. It highlights that these devices can be powered by solar-charged batteries in remote areas and may be paired with flame sensors to shut off gas flow. Economically, the primary driver is the saving of natural gas that would otherwise be burned as a pilot flame, with a reported payback period of less than three years and a methane reduction of 168,000 standard cubic feet per year per device replacing a flame that is out for 24 hours annually.

The document outlines a technique where foaming agents (soap) are injected into gas production wells to facilitate the removal of liquids, thereby reducing the frequency of gas purging and the associated methane emissions. Reported results for a single well show a methane emission reduction of 2,520 thousand cubic feet per year.